Coordinated Care Organizations Forum

Email Exchange with Cindy Brown (Division of Medicaid) Regarding 5% Assessment and Related CCO Issues

From: Linda Piazza [mailto:llpiazza@bellsouth.net]
Sent: Monday, December 16, 2019 4:56 PM
To: Cindy S. Brown
Subject: Speech Therapy 5% Assessment by Managed Care Organizations

Dear Ms Brown,

My name is Linda Piazza.  I am MSHA V.P. Healthcare Committee.   I am contacting you in reference to several issues that Private Practice Mississippi Speech Language Pathologists are experiencing with Mississippi Medicaid HMO’s.  A letter was sent to Sharon Jones weeks ago regarding these issues.  To date there has been no response.  Therefore, since the issues addressed in that letter are persisting and are causing much distress and difficulties for therapist who are diligently working to provide medically necessary speech/language therapy services to children covered under the EPSDT benefit. Therefore, I am forwarding that letter to you as it provides detailed information regarding these issues.  I will also attach documents relating to these concerns.

The following are our main issues of concern:

1. The 5% Assessment by HMO’s who are for profit entities rather that a not -for profit State Medicaid Agency.  There is no Legislative authority granting HMO’s permission to assess providers the 5% assessment.  The Division of Medicaid was authorized by legislative action to assess provider 5% of their reimbursement rate when the DOM had a budget deficit or reasonably anticipated a budget deficit in the coming year.  There was no budget deficit last year or this year and no anticipated budget for the coming fiscal year.

2. In addition to the implementation of the 5% assessment on speech therapy providers, United and Magnolia are assessing the 5% retroactively to beginning of 2018.   This is a significant burden to private practice speech therapists who are trying to keep their practice and continue to provide speech therapy services to children.  There is nothing in administrative code or legislation that allows this assessment.    

3. Providers report Inconsistent Coverage and Authorization of services from DOM, and each HOM.   Denial of services requested are made by reviewers who do not have an expertise in the enrollee’s healthcare therapy needs.

4. Children are denied coverage at times, based on standard scores or lists of diseases. HRSA- Maternal and Child Health states in reference to Medically Necessary Treatment for Children: “Hard, fixed or Arbitrary limits (e.g., based on dollar amounts, standard deviations from the norm, lists of diseases) are not permitted.

These are some of the problem areas reported to me by speech/language pathologists in private settings.

Thank you so much for your time and attention to these really important issues.  I would really appreciate any help that you can give.  I am also happy to have a face to face meeting with you and some of the speech therapists to discuss these problem areas that interfere needed services for children. We would all benefit from respectful informative discussions and problem solving.

 

Thanks,
Linda

Linda L. Piazza, MS CCC SLP
Vice President - HealthCare, Mississippi Speech and Hearing Association (MSHA)
Principal Associate, Speech Care Associates



From: Cindy S. Brown <Cindy.Brown@medicaid.ms.gov>
Sent: Tuesday, December 17, 2019 1:58 PM
To: Linda Piazza <llpiazza@bellsouth.net>
Subject: RE: Speech Therapy 5% Assessment by Managed Care Organizations

Great morning Ms. Piazza,

Thank you so much for reaching out to Medicaid.  These concerns where sent earlier and are being sent to the CC Plans to be addressed during the 2020 MSHA Conference.

Thank you,

Cindy S. Brown
Outreach Coordinator | Office of Client Relations
Mississippi Division of Medicaid
550 High Street, Suite 1000 | Jackson, Mississippi 39201
Phone (601) 359-6136
Email  Cindy.Brown@medicaid.ms.gov
Website http://www.medicaid.ms.gov

DOM-Logo-Email-Signature
Confidentiality Note: This message and all attachments are confidential and/or proprietary to the Mississippi Division of Medicaid, and the use, disclosure, copying or distribution by any means, to anyone other than the intended recipient without the prior written permission of the Mississippi Division of Medicaid, is strictly prohibited. The information contained in and attached to this message is intended for the exclusive use of the individual or entity named herein. If you have received this message in error, please notify the sender by replying to the email or contact the telephone number above for instructions on how to delete or return the information without additional disclosure. Thank you for your assistance in the protection of confidential information.


From: Linda Piazza <llpiazza@bellsouth.net>
Sent: Friday, December 20, 2019 1:56 PM
To: 'Cindy S. Brown' <Cindy.Brown@medicaid.ms.gov>
Subject: RE: Speech Therapy 5% Assessment by Managed Care Organizations

Dear* Ms. Brown,

Thank you so much for responding to my email to you.  There are just a few points that I would like to make concerning the issues that I described in my email to you.  

1. Since the issue of the 5% assessment and the retroactive assessment of the 5% will not be addressed by DOM until the MSHA Annual Conference,  there  will obviously be no relief for providers regarding the retroactive assessment.  I will inform the membership of this situation. 

2. The concerns that I presented regarding consistency of prior authorization of services and the use of reviewers who are not speech therapist for approvals/denials of speech therapy prior authorization of services are based on Federal Code for Medicaid Managed Care Regulations.

3.  Children are denied coverage at times, based on standard scores or lists of diseases. HRSA- Maternal and Child Health states in reference to Medically Necessary Treatment for Children: “Hard, fixed or Arbitrary limits (e.g., based on dollar amounts, standard deviations from the norm, lists of diseases) are not permitted.    This concern is, I think, self-explanatory.   This document is found on the CMS Website.

All of these issues have previously been addressed with the Division of Medicaid. 

I think that I speak for my colleagues, when I say that we do not feel that our services are not always seen as being vital to children with speech/language/hearing disorders. I am attaching an article by ASHA which discusses the dramatic increase in speech problems in children over the past decade. It is stated in the article, “While the reasons behind the marked  increase in speech and hearing problems may not be fully clear, the data argue for continued improved awareness among parents and the larger public about these as well as speedy intervention at their earliest warning signs,”  said Elizabeth McCrea, PH.D, CCC-SLP, ASHA 2014 President.  “Unlike many other conditions, early intervention often has the potential to prevent or reverse a communication disorder---or at least dramatically reduce the negative consequences it has on children’s academic and social success as well as their overall development. That is why ASHA urges parents to educate themselves about the signs and seek an assessment from a speech-language pathologist or audiologist if they have any concerns at all.”     “….we want to encourage parents to avoid the “wait and see” approach which is all too common with speech and hearing disorders. “The earlier we reach a child, the more successful, the less expensive, and the shorter the course of treatment.  By delaying an assessment and/or treatment to see if a child outgrows a potential disorder, parents may be missing a key window of opportunity.”    This is the information that needs to be provided to Medicaid and Managed Care Organizations.    Speech/language therapy services are vital to children who have speech/language disorders.  And, these services are controlled and are cost effective.

I read in the 2018 Medicaid Board Meeting Minutes, the statement by Drew Snyder, Medicaid Executive Director, in which he expressed that while children are the largest number of Medicaid enrollees, they are the least utilizer of services and the least costly.    

We, as speech language pathologists, are an autonomous profession, ASHA Certified and bound by a strict code of ethics by ASHA and MSHA.   Our desire is to participate in the Medicaid Managed Care Program not as adversaries, but as partners in providing needed services to children with speech/language/hearing disorders.   If we all follow state and federal regulations, this can be achieved, resulting in timely, effective and cost-effective early intervention treatment services for children diagnosed with speech/language/hearing disorders.  And, thus eliminating more costly treatment and long term consequences to children who do not received these early intervention services.     This should be a shared goal.

Thank you very much for your time and attention to these matters.

 

Linda L. Piazza, MS CCC SLP
Vice President - HealthCare, Mississippi Speech and Hearing Association (MSHA)
Principal Associate, Speech Care Associates

Topics and discussions concerning Magnolia processes and correspondence.
Topics and discussions concerning Molina processes and correspondence.
Topics and discussions concerning United Health Care processes and correspondence.


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